Heard's Estate

10 Pa. D. & C. 119, 1927 Pa. Dist. & Cnty. Dec. LEXIS 398
CourtPennsylvania Orphans' Court, Erie County
DecidedMarch 22, 1927
DocketNo. 84
StatusPublished

This text of 10 Pa. D. & C. 119 (Heard's Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Erie County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heard's Estate, 10 Pa. D. & C. 119, 1927 Pa. Dist. & Cnty. Dec. LEXIS 398 (Pa. Super. Ct. 1927).

Opinion

Clark, P. J.,

Julia M. Rathbun was appointed adminis-tratrix of the estate of Francis J. Heard, deceased.

The accountant charges herself with $9757; claims credit of $1222.85; leaving a balance due of $8534.15, for distribution. The $9757 came from war risk insurance, and to this, since the filing of the account, $110 were received from another source, thus making total balance of $8644.15 in the custody of the administratrix.

Francis J. Heard was a soldier in the World War and, from reports of his officer, was killed in action July 15, 1918, in France; and was insured under the War Risk Insurance Act of Oct. 6, 1917, 40 Stat. at L. 409, for $10,000; and designated his grandmother, Louise Parkhurst Cook, the beneficiary; and payments were made to her up to the date of her death, Feb. 18, 1919. She made her will Dec. 16, 1918, and gave to Julia M. Rathbun, the administratrix, household furniture and fixtures and “one-half of my estate, including one-half of the Government life insurance made to me by grandson, Francis J. Heard, . . . and to my grandson, Merl J. Cook and my granddaughter, Ethel Louisa Williams, the remaining half of my estate, including one-half of the Government life insurance. . . .” Feb. 15, 1919, by her codicil, these bequests were changed, and in it she gave “all payments to which I may now be entitled or would be were I to live, payable upon a policy issued by the Bureau of War [120]*120Risk Insurance to Francis J. Heard in which policy I am named as beneficiary, after paying my debts and funeral expenses, first, payments to be paid to my sister, Mrs. Julia M. Rathbun, for and during her life and after her death, balance of payments to be paid to Ethel L. Williams, my granddaughter, of Salt Lake City, Utah.”

Evidently the testatrix believed that this war risk insurance after her death would be a part of the assets of her estate; briefly, that she had a vested interest in it and, as such, she could dispose of it by her will.

Accrued and unpaid payments up to the time of her death are a part of her estate and that is all; the remaining insurance after her decease is not an asset of her estate and she cannot dispose of it by her will.

It has been contended that the interest of a designated beneficiary under the provisions of the War Risk Insurance Act of Oct. 6, 1917, was a vested interest, and that to deprive such person of it by the subsequent legislation of the Act of Dec. 24, 1919, ch. 16, § 13, 41 Stat. at L. 371, 375, would be taking the property without due process of law.

The designated beneficiary cannot dispose of the insurance by will; it is not vested, and it has been so decided by the Federal courts.

In the U. S. District Court, Middle District of Pennsylvania, it was set forth, July 2, 1923, Witmer, J., in Gilman Heirs v. United States, 290 Fed. Repr. 614, that: “In the case of Cassarello v. United States (D. C.), 271 Fed. Repr. 486, affirmed by the Circuit Court of Appeals, 279 Fed. Repr. 396, this court states that the contract between the Government and the insured is not an ordinary contract of insurance, and held that, since in principle it lacked the character of a vested interest, the same could not be passed by the last will of the designated beneficiary.”

The decision in the Gilman Heirs case, supra, was affirmed by the Circuit Court of Appeals, 294 Fed. Repr. 422, Jan. 2, 1924.

And it was held in Hurst v. United States (D. C.), 283 Fed. Repr. 600, that there was no disturbance of a vested right by the Act of 1919. The decision in this case was affirmed by the Circuit Court of Appeals, Sixth District, Jan. 11, 1924, 294 Fed. Repr. 417.

The United States Supreme Court has decided that there was no vested interest, and Gilman Heirs v. United States, supra, and Hurst v. United States, supra, were cited with approval in the opinion of Justice Holmes, March 1, 1926, in White v. United States and Reeves, reported in Advance Opinions 1925-1926, 70 L. Ed., No. 9, pages 316, 317, March 15, 1926, and [that case] affirms the decision of the District Court, Eastern District of Virginia, reported in 299 Fed. Repr. 855.

The reasons for these decisions are fully set forth in them and can be examined by any one interested in the subject-matter; we have not attempted to recite them.

The Act of Oct. 6, 1917, 40 Stat. at L. 409, designated the beneficiaries from which classification the soldier could make his selection in favor of whom the insurance might run. These beneficiaries were limited by the act, which provides that: “The insurance shall not be assignable, and shall not be subj'eet to the claims of creditors of the insured or of the beneficiary. It shall be payable only to a spouse, child, grandchild, parent, brother or sister, and also during total and permanent disability to the inj’ured person, or to any or all of them.”

As to who are included or intended or meant by the terms “child,” “grandchild,” “parent,” etc., the designated persons, see same act, page 401. The term “parent” includes a father, mother, grandfather, grandmother, step[121]*121father and stepmother, either of the person in the service or of the spouse. Hence, the soldier’s designation of his grandmother as the beneficiary was permissible.

And this act further provides: “Subject to regulations, the insured shall at all times have the right to change the beneficiary or beneficiaries of such insurance without the consent of such beneficiary or beneficiaries, but only within the classes herein provided. If no beneficiary within the permitted class be designated by the insured, either in his lifetime or by his last will and testament, or if the designated beneficiary does not survive the insured, the insurance shall be payable to such person or persons within the permitted class of beneficiaries as would, under the laws of the state of the residence of the insured, be entitled to his personal property in case of intestacy.”

Note that payment of the insurance is limited to the “permitted class of beneficiaries,” under the conditions named; in the case being considered, the designated beneficiary survived the insured, but is now dead.

In the case of Cassarella v. United States, supra, Judge Witmer has given a very informative decision upon various questions; among others, that the rules and regulations prescribed by a department of the Government in pursuance of statutory authority have the force of law, and cites several cases of the Federal courts, including the Supreme Court, in support.

Authorized by Congress, the Director of the Bureau of War Risk Insurance did make certain rules and regulations, and they are binding; and, further : “A contract made in pursuance of a Federal statute must be construed with reference to such statute and cannot be controlled by the state laws or decisions,” and authorities are cited sustaining this, and reference is made to an opinion by Mr. Justice Pitney, of the United States Supreme Court, in the case of the Duplex Printing Press Co. v. Deering, etc., 254 U. S. 443, 41 U. S. Sup. Ct. Reps. 172, 165 L. Ed., wherein it was held that the debates in Congress by members are not a safe guide generally, but that the reports of committees may be considered in determining the legal intent where the meaning is obscure and this has been “. . .

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Related

Duplex Printing Press Co. v. Deering
254 U.S. 443 (Supreme Court, 1921)

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10 Pa. D. & C. 119, 1927 Pa. Dist. & Cnty. Dec. LEXIS 398, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heards-estate-paorphcterie-1927.